IR 05000373/2021002
| ML21302A139 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/01/2021 |
| From: | Kenneth Riemer NRC/RGN-III/DRP/B1 |
| To: | Rhoades D Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2021002 | |
| Download: ML21302A139 (27) | |
Text
SUBJECT:
LASALLE COUNTY STATION - INTEGRATED INSPECTION REPORT 05000373/2021002 AND 05000374/2021002
Dear Mr. Rhoades:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at LaSalle County Station and discussed the results of this inspection with Mr. J. Washko, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at LaSalle County Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at LaSalle County Station.
November 1, 2021 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Kenneth R. Riemer, Chief Branch 1 Division of Reactor Projects Docket Nos. 05000373 and 05000374 License Nos. NPF-11 and NPF-18
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000373 and 05000374
License Numbers:
Report Numbers:
05000373/2021002 and 05000374/2021002
Enterprise Identifier:
I-2021-002-0033
Licensee:
Exelon Generation Company, LLC
Facility:
LaSalle County Station
Location:
Marseilles, IL
Inspection Dates:
April 01, 2021 to June 30, 2021
Inspectors:
G. Edwards, Health Physicist
R. Elliott, Senior Resident Inspector
M. Jones, Reactor Inspector
G. O'Dwyer, Reactor Engineer
W. Schaup, Senior Resident Inspector
R. Zuffa, Illinois Emergency Management Agency
Approved By:
Kenneth R. Riemer, Chief
Branch 1
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at LaSalle County Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Follow Station Procedures Results in Scaffold Attached to Safety-Related Equipment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000374/2021002-01 Open/Closed
[P.3] -
Resolution 71111.15 The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, "Instructions,
Procedures and Drawings," for the licensee's failure to follow station procedures MA-AA-716-0025, "Scaffold Installation, Modification, and Removal Request Process," Revision 18 and MA-AA-796-024, "Scaffold Installation, Inspection and Removal," Revision 12. Specifically, the licensee erected a scaffold that was anchored to safety-related equipment without prior approval. Additionally, the scaffold was not being tracked administratively and, as a result, was installed in the plant during operations for great than 90 days without a 10 CFR 50.59 review performed or engineering approval making the installation a permanent scaffold.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On May 1, 2021, the unit was down powered to approximately 40 percent to perform a drywell entry to add oil to the reactor recirculation pumps, perform channel distortion testing, turbine control valve testing, and scram time testing. The unit was returned to full power on May 2, 2021. On May 24, 2021, the unit was down powered to 82 percent to perform repairs on turbine control valve #1 linear variable differential transformer #3 cable. The unit was returned to full power on May 25, 2021 and remained at rated thermal power for the remainder of the inspection period.
Unit 2 began the inspection period in a refueling outage. On April 20, 2021, Unit 2 was synced to the grid and reached full rated thermal power on April 21, 2021. On April 22, 2021, the unit was down powered to approximately 82 percent to perform a rod sequence exchange and returned to full rated thermal power on the same day. On June 5, 2021, the unit was down powered to approximately 72 percent to perform a rod sequence exchange and channel distortion testing. The unit was returned to full power on June 6, 2021 and remained at rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on-site as local COVID-19 conditions permitted.
As part of their on-site activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of extreme high temperatures for the following systems: Lake screen house, switchyard, and station transformers on May 19, 2021.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 1A emergency diesel generator (EDG) on April 28, 2021
- (2) Unit 2 reactor core isolation cooling during Division 3 work on May 24, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 standby liquid control on June 16, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone 4E2, Unit 2 auxiliary building, elevation 731'-0", auxiliary equipment room with unavailable fire risk important components on May 24, 2021
- (2) Fire Zone 4D1, Unit 1 auxiliary building, elevation 749'-0", cable spreading room on June 30, 2021
- (3) Fire Zone 4D2, Unit 2 auxiliary building, elevation 749'-0", cable spreading room on June 30, 2021
- (4) Fire Zone 5A4, Unit 1 auxiliary building, elevation 749'-0", balance of plant cable area on June 30, 2021
- (5) Fire Zone 4E1, Unit 1 auxiliary building, elevation 731'-0", auxiliary equipment room on June 30, 2021
71111.07T - Heat Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)
The inspectors evaluated heat exchanger/sink performance on the following:
(1)2VY01A Unit 2 Train A residual heat removal pump room cooler (2)2E22-S001 Unit 2 high pressure core spray diesel generator jacket water heat exchanger
Ultimate Heat Sink (IP Section 03.04) (1 Sample)
Specifically, Section 03.05.b was completed.
- (1) ultimate heat sink underwater containment device capacity and structural integrity
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during reactor plant startup on Unit 2 at the completion of Refueling Outage L2R18 on April 17 and 19, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated out-of-the-box exam S-21-3-OBE B on June 8, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Unit 2 online risk Yellow for planned maintenance on the Division 3 EDG on April 27, 2021
- (2) Unit 2 shutdown safety Yellow due to reduced inventory while draining the reactor cavity to support head reassembly on April 13, 2021
- (3) Unit 2 online risk Yellow for planned maintenance on the high-pressure core spray system on April 27, 2021
- (4) Unit 2 online risk action Green for planned Division 3 direct current system outage on May 24, 2021
- (5) Unit 1 online risk action Green for planned high pressure core spray cooler 1VY02A cleaning on May 26, 2021
- (6) Units 1 and 2 Yellow risk with 0 EDG out of service for maintenance on May 10, 2021
- (7) Unit 2 emergent work due to half scram caused by loss of the 2A reactor protection system motor generator set on June 1, 2021
- (8) Units 1 and 2 emergent work on the unit common diesel generator day tank on June 14, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Action Request 4412402, "Air Void Found at 1RH03CB"
- (2) Action Request 4425204, "As Found Flow Low on 2VY02A During LOS-DG-Q3"
- (3) Action Request 4429239, "0 Diesel Generator Day Tank Leaking Fuel Oil"
- (4) Action Request 4372880, "NRC Identified - Inter-Cell Resistance Readings Not Taken"
- (5) Action Request 4425379, "NRC Identified - Unit 2 Division 2 Switchgear Room Scaffolding"
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 2 Division 3 125 Vdc distribution panel temporary charger
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Unit 2 post-maintenance testing on the 'C' and 'G' intermediate range meters on March 11 and 13, 2021
- (2) Unit 2 scram time testing after control rod drive mechanism and rod channel replacement on April 17, 2021
- (3) Unit 2 reactor core isolation cooling pump operability and in-service test on April 22, 2021
- (4) Unit 2 safety relief valve testing following replacement under Work Order 4705465
- (5) Common Unit EDG follow failure of field to flash during post-maintenance testing run on May 12, 2021
- (6) Unit common diesel generator day tank after leak on manway cover flange on June 14, 2021
- (7) Unit 1 post-maintenance testing of the low-pressure core spray system after routine maintenance on June 9, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated Refueling Outage L2R18 activities from February 22, 2021 to April 18, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) LOS-RI-Q3, Unit 2 reactor core cooling isolation cooling system pump operability and valve in-service tests in conditions 1, 2, and 3 on April 19, 2021, per Work Order 4902826
- (2) LOS-VG-M1, Unit 2 standby gas treatment system operability and in-service test on April 20, 2021, per Work Order 5135547
- (3) LOS-NP-R2, Unit 2 reactor vessel leakage test on April 16, 2021, per Work Order 4902825
- (4) LOS-DG-R2B, 2B diesel generator 24-hour run surveillance on April 27, 2021
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) LOS-RH-Q1, Unit 1 residual heat removal system operability and in-service test on April 5, 2021
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) LOS-FSG-SA1, FLEX semi-annual equipment surveillance on May 14, 2021, per Work Order
RADIATION SAFETY
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
(1)station standby gas treatment system
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the internal dosimetry program implementation.
(1)worker inhalation event investigation performed by whole body count on March 8, 2021 (2)worker inhalation event investigation performed by whole body count on April 4, 2021
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situation:
(1)application of NRC-approved external dosimetry methods (i.e., EDEX) performed by the licensee on March 3, 2021
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (5 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
(1)portable ion chamber (RO 20) stored on the refuel floor (2)portable air monitoring system (AMS 4) in use on the refuel floor (3)portable frisker (RO 3) stored at the turbine building entrance/exit (4)personnel contamination monitor (CM 11) stored at the turbine building entrance/exit (5)portable ion chamber (RO 20) stored in the reactor building Unit 2 hatch access control point
Calibration and Testing Program (IP Section 03.02) (10 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Mirion AMP 100, Serial Number (SN) #5095-044
- (2) Mirion AMP 200, SN #7707-034
- (3) Thermo AMS-4, SN #1860
- (4) Ludlum Model 3, SN #269139
- (5) Ludlum Model 177, SN #315540
- (6) Thermo Fisher PM 12, SN #1247
- (7) Mirion RAM GAM 1, Asset Number (AN) #079476
- (8) Eberline RO20, SN #3549
- (9) Mirion Telepole, AN #334713
- (10) Thermo Fisher SAM-12, SN #12088 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
(1)standby gas treatment wide range gas monitor (2)station vent stack wide range gas monitor
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI02: RCS Leak Rate Sample (IP Section 02.11)===
- (1) Unit 1 (April 1, 2020 through March 31, 2021)
- (2) Unit 2 (April 1, 2020 through March 31, 2021)
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends and did not identify any that might be indicative of a more significant safety issue.
Annual Follow-Up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Action Request 4404013, "Residual Water Found in Tendon 213B"
- (2) Anchor Darling double disc gate valve 2G33F001 PI&R assessment
INSPECTION RESULTS
Failure to Follow Station Procedures Results in Scaffold Attached to Safety-Related Equipment Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000374/2021002-01 Open/Closed
[P.3] -
Resolution 71111.15 The inspectors identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings," for the licensee's failure to follow station procedures MA-AA-716-0025, "Scaffold Installation, Modification, and Removal Request Process,"
Revision 18 and MA-AA-796-024, "Scaffold Installation, Inspection and Removal,"
Revision 12. Specifically, the licensee erected a scaffold that was anchored to safety-related equipment without prior approval. Additionally, the scaffold was not being tracked administratively and, as a result, was installed in the plant during operations for great than 90 days without a 10 CFR 50.59 review performed or engineering approval making the installation a permanent scaffold.
Description:
On May 24, 2021, while conducting a plant tour, after entering the Unit 2 Division 2 switchgear room, the inspectors noted a scaffold erected near the switchgear room cooling ventilation system. Upon further investigation, the inspectors noted the following. Based on the attached paperwork, the scaffold was designated as a non-permanent scaffold that was installed on October 23, 2020. The scaffold was physically anchored/attached to the safety-related ventilation system in two different locations. A post-erection inspection was not performed by operations or by engineering. The scaffolding had been erected for greater than 90 days and the work associated with the scaffold was completed on November 23, 2020. The licensee documented this in their corrective action program as Action Request 4425379. The licensee removed the scaffold the following day.
The inspectors reviewed the applicable procedures and documentation and determined the following:
Station procedure MA-AA-716-025, "Scaffold Installation, Modification, and Removal Request Process," states the following:
Step 2.8, defines a non-permanent scaffold as temporary access or support structures utilizing scaffold material erected in support of maintenance or operations activities that are to be removed at the completion of the activities. These temporary access structures are not intended to be left in place for more than 90 days of power plant operations. The scaffold was designated as temporary scaffold and was left in place for greater than 90 days of power plant operations.
Step 3.6 states that the scaffold coordinator/designee is responsible for the coordination of erection of the status of all scaffolds on site. Maintaining a log or electronic equivalent of the status of all scaffolds and reviewing the log to ensure that any scaffolds approaching their 90-day limit are removed or converted to a permanent scaffold or requesting and individual 10 CFR 50.59 review be performed for the individual scaffold required to be left in place beyond 90 days. The scaffold was not in the scaffold log and was not removed, converted to a permanent scaffold, nor had a request for a 10 CFR 50.59 review performed to allow the scaffold to remain in place after 90 days.
Step 4.1.5 states scaffold coordinator/designee review MA-AA-716-F-1 and coordinate completion of Section D.
Step 4.1.5.4 states that operations/designee approve post-erection inspections required by operations prior to approving scaffold for use. Operations did not perform a post-erection inspection prior to approving the scaffold for use.
Step 4.1.5.5 states engineering approve post-erection inspections required by engineering. Engineering did not perform a post-erection inspection that would be required since the scaffold was anchored off a safety-related component.
Step 4.7.1 states that the scaffolding coordinator/designee perform a monthly review of the scaffold log to: 1) ensure scaffolds are removed prior to 90 days from installation date; and 2) if a scaffold must remain in place beyond 90 days from the installation date, then engineering should be notified.
No reviews were performed and engineering was not notified.
Station procedure MA-AA-796-024, "Scaffold installation, inspection, and removal," states the following:
Step 3.1.7 states that scaffold shall not be attached to plant equipment without prior approval.
The scaffold was anchored to safety-related equipment in two locations without prior engineering approval.
Step 3.2.2 states that as a minimum, seismic scaffolds shall comply with specific requirements of approved procedures, unless approved by engineering. The scaffold did not comply with station procedure NES-MS-04.1, "Seismic Prequalified Scaffolds," Revision 7 and required engineering approval, which was not obtained.
Step 4.3.4 states to inspect erected scaffold for compliance with scaffold request form and requirements of this procedure.
Step 4.3.11 states to update the scaffold log/PIMS/Passport or scaffold coordinator, as necessary, to indicate a status of scaffold. The scaffold log did not contain an entry for this scaffold.
Based upon the above, the inspectors determined there were multiple examples of the failure of station personnel to follow multiple procedures related to the installation and control of a temporary scaffold that resulted in the scaffold being anchored to a safety-related component in the plant that was not previously analyzed for this condition for seismic qualification. A subsequent calculation by engineering determined that the safety-related equipment would have functioned during a design basis earthquake.
Corrective Actions: The licensee immediately removed the scaffold and documented the condition in their corrective action program as Action Request 4425379. Additionally, the licensee performed Engineering Change (EC) 634359 to determine if the condition affected the seismic qualification of the safety-related equipment.
Corrective Action References: Action Request 4425379
Performance Assessment:
Performance Deficiency: The inspectors identified multiple examples of the failure to follow station procedures MA-AA-716-025 and MA-AA-796-024 related to the control and installation of a temporary scaffold that were contrary to 10 CFR 50, Appendix B, Criteria V, "Instructions, Procedures, and Drawings," and therefore was a performance deficiency. Specifically, the licensee installed a scaffold that was attached to safety-related equipment without prior approval, did not follow procedural requirements to track the scaffold, did not ensure that the temporary scaffold was installed in the plant for less than 90 days, did not review under 10 CFR 50.59, and did not convert to a permanent scaffold.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the scaffold being attached to the ventilation system resulted in reasonable doubt about the equipments seismic qualifications, which reduced assurance in the equipments availability and reliability and required the licensee to perform a calculation, and to immediately remove the scaffold to resolve the seismic concerns.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened as very low safety significance (Green) because it did not result in the loss of operability or functionality of a mitigating system.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance.
Specifically, in NRC Integrated Inspection Report 05000373/2018004, the inspectors issued a similar violation which the licensee entered into their corrective action program as Action Request 4185035 that performed a causal product that provided corrective actions that have not been effective.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by instructions, procedures and drawings, of a type appropriate to the circumstance and shall be accomplished in accordance with the instructions, procedures or drawings.
Step 3.6 of procedure MA-AA-716-025, "Scaffold installation, modification, and removal request process," states that, the scaffold coordinator/designee is responsible for the coordination of erection of the status of all scaffolds on site. Maintaining a log or electronic equivalent of the status of all scaffolds and reviewing the log to ensure that any scaffolds approaching their 90 day limit are removed or converted to a permanent scaffold or requesting an individual 10 CFR 50.59 review be performed for the individual scaffold required to be left in place beyond 90 days.
Step 4.1.5.4 of procedure MA-AA-716-025, "Scaffold installation, modification, and removal request process," states that, operations/designee approve post-erection inspections required by operations prior to approving scaffold for use.
Step 4.1.5.5 of procedure MA-AA-716-025, "Scaffold installation, modification, and removal request process," states engineering approve post-erection inspections required by engineering.
Step 3.1.7 of procedure MA-AA-796-024, "Scaffold installation, inspection, and removal,"
states that scaffold shall not be attached to plant equipment without prior approval.
Step 3.2.2 of procedure MA-AA-796-024, "Scaffold installation, inspection, and removal,"
states that as a minimum, seismic scaffolds shall comply with specific requirements of approved procedures, unless approved by engineering.
Contrary to the above, from October 23, 2020 until May 25, 2021, the licensee failed to ensure an activity affecting quality was accomplished in accordance with instructions, procedures, or drawings. Specifically, the scaffold in the Unit 2, Division 2 switchgear room was installed and anchored to safety-related equipment for a period in excess of 90 days, without being recorded in the scaffold log and was not removed, converted to a permanent scaffold, or had a request for a 10 CFR 50.59 review performed to allow the scaffold to remain in place after 90 days. The scaffold did not have a post-erection inspection completed by operations or engineering and was not built-in accordance with pre-approved seismic scaffolding instructions or had engineering prior approval to be attached to a safety-related component.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Anchor Darling Double Disc Gate Valve 2G33F001 PI&R Assessment 71152 The inspectors reviewed the licensees evaluation (EC 626108, Revision 4) documenting the acceptability of deferring permanent repairs to Unit 2 reactor water cleanup (RWCU) inboard isolation valve 2G33-F001 from Refueling Outage (RO) L2R18 (in 2021) to RO L2R19 (in 2023). The valve was originally scheduled to be repaired during RO L2R17 (in 2019) but was deferred to RO L2R18 (2021) due to dose concerns. Valve 2G33-F001 is an Anchor Darling double disc gate valve, and the stem and wedge replacements for the valve are because of a 10 CFR Part 21 Notification, Wedge Pin Failure in Anchor Darling Motor Operated Double Disc-Gate Valves with Threaded Stem to Upper Wedge Connections, from Flowserve to the USNRC on July 11, 2017. The reason for the most recent deferral was based upon high local dose rates at the valve and the inability to achieve the desired boundary isolation as documented in Action Request 4406321.
Engineering Change 626108, Revision 4, recommended valve 2G33-F001 be permanently repaired during RO L2R18 (in 2021) but stated it was acceptable to defer the permanent repairs to RO L2R19 (scheduled for 2023) provided a number of conditions were met.
acceptable as-found stem rotation values in RO L2R18 (2019)
no unanalyzed trace abnormalities detected during RO L2R18 (2019)permanent repairs are made to the valve no later than RO L2R19 (in 2023)
the station evaluates the degraded condition in accordance with existing plant processes/procedures for evaluating risk
the valve remains open during the entire operating cycle to retain the condition found during valve diagnostic testing performed on March 3, 2021, and to ensure the stem-to-disc connection remains intact which provides assurance the valve is capable of performing its safety function The inspectors independently reviewed the licensees thrust and torque design, historic operational information, RO L2R18 stem rotation checks and diagnostic traces, Operability Evaluation 17-002 Revision 4, the commitment management program, and the as-found condition documentation for the Unit 1 1G33-F001 valve. Valve 1G33-F001 is the Unit 1 RWCU inboard isolation valve with the same make and model, manufactured in the same year, and have a similar operational history.
Based upon the licensees evaluation documented in EC 626108, no immediate safety issue was identified. The inspectors independently reviewed the RO L2R18 stem rotation checks, diagnostic traces and did not identify any issues indicative of a broken pin, and/or loose stem. However, as discussed in NRC Special Inspection Report 05000373/2017009 and 05000374/2017009, conducted following the failure of an Anchor Darling double disk gate valve on LaSalle Unit 2 stem rotation checks and diagnostic testing were not reliable indicators to determine if stem-to-wedge joint degradation had occurred, nor did these tests demonstrate that the valve would perform its safety function in the future. Specifically, the SIT report stated:
The team reviewed the licensees evaluation of the 2015 2E22-F004 valve diagnostics to determine if the stem-to-wedge degradation was able to be identified. Specifically, the team evaluated abnormalities in the diagnostic traces. The licensees basis for the 2015 as-found and as-left thrust trace abnormalities was that the stem was a slightly less self-locking during the period of relaxation following a stem lubrication maintenance activity. In addition, the licensee stated that since the closed seating thrust traces showed normal and consistent behavior, there was no corresponding evidence for the seating thrust traces that suggested that stem-to-disc connection was re-threading nor were there any other observed diagnostic trace abnormalities that would indicate a loose stem-to-disc connection. The team agreed that this was a reasonable conclusion. Specifically, the team agreed that the diagnostic traces performed by the licensee were not able to identify that degradation was occurring or the valve would eventually fail.
Additionally, the team determined that the stem rotation checks performed at the site were not a reliable indicator that stem-to-wedge degradation was occurring or would occur in the future. This determination was based upon the minimum rotation that the 2E22-F004 valve demonstrated just prior to failure. Additionally, the licensees failure analysis supported that the failure could have occurred with less than 5 degrees of stem rotation.
The team concluded that the stem rotation checks and valve diagnostic testing were not reliable indicators to determine if stem-to-wedge joint degradation had occurred, nor did these tests demonstrate that the valve would perform its safety function in the future.
The inspectors concluded the licensees self-imposed condition of maintaining 2G33-F001 open during the entire cycle provides additional defense-in-depth to reasonably conclude the valve is capable of closing.
The licensees reasons for deferral in both the L2R17 (2019) and L2R18 (2021) refueling outages are characterized by the inspectors as missed contingency planning opportunities. The potential challenges of higher-than-expected dose rates or maintenance isolation issues are not uncommon in the industry and could have been foreseen and managed in a manner that resolved the non-conforming 10 CFR Part 21 issue at the site by now.
Additionally, the inspectors pointed out that the planning for repairs in the recent L2R18 RO should have been more thorough with contingencies to reasonable assure that the work could be completed. Specifically, first it was determined that single valve isolation would be used to perform the work but not only single valve isolation but single valve isolation to the pressure vessel containing fuel that could have presented water inventory control issues. Second it was known that the bottom head drain line had foreign material in the line that could prevent fully closing the valve to provide isolation for the required work and that the foreign material would significantly increase the dose required to perform the work. Third the licensee had a commitment to the NRC to complete the work. Finally, the work had already been deferred once from 2019 to 2021 for the exact same reasons provided to defer the work until 2023 to the next RO with the inspectors noting that from 2019 to 2021 no additional planning was performed to provide for reasonable success path to repair the valve.
Specifically, to address the concern if the initial stem preload on the press fit collar during assembly was correctly applied and or lost during operation, if the stem pin had broken, and if the stem-to-disc joint assembly had loosened and/or resulted in thread degradation and wear. Instead of the non-conforming condition being corrected at the next available opportunity, the licensee has pushed the planned corrective action out to approximately 6 years from original discovery. Although reasonable assurance for continued operability has not been lost, the actual condition of the 2G33-F001 stem-to-disc connection is still in question because of the nature of the non-conforming design and manufacturing condition and lack of thrust and torque data for every cycled operation of 2G33-F001 including historic testing setup. Due to the missed planning opportunities, the licensee is carrying forth unnecessary operational risk for another cycle (approximately 2 years).
Observation: Residual Water Found in Tendon 213B 71152 The inspectors reviewed Action Request 4404013, "Residual Water Found in Tendon 213B,"
as a sample for annual selected issues for follow-up focusing on the following performance attributes of IP 71152:
complete, accurate, and timely documentation in the corrective action program
consideration of the extent of condition and cause, generic implications, common cause, and previous occurrences
evaluation and timely disposition of operability and reportability issues
classification and prioritization of the resolution of the problem commensurate with safety significance
identification of corrective actions, which were appropriately focused to correct the problem completion of corrective actions in a timely manner commensurate with the safety significance of the issue
operating experience is adequately evaluated for applicability and applicable lessons learned are communicated to appropriate organizations and implemented The inspectors determined that the licensee had appropriately followed station procedures and the station's corrective action program to ensure all elements inspected were adequately addressed. The inspectors discussed additional areas for the licensee to consider as they address the issue. These areas were captured as assignments under Action Request 4427327 and detailed as follows:
Extent of Condition: Licensee corrective action documents have not provided justification for concluding that the water intrusion is limited to the V213B tendon top anchor, particularly when the cause of water intrusion has not been identified. Inspection of the remaining two tendons did not include removal of the grease caps for examination of the anchor components or inspection at the bottom end to identify trace of water. As a result, there does not seem to be enough data to conclude that water intrusion has not occurred in the remaining Group B tendons.
Unverified Assumption: The three Unit 2 anchors were inspected to close out an unverified assumption documented in the 90-day post in-service inspection report to the NRC in 2003 to support exclusion of Group B tendons from future in-service inspection Section XI, IWL examination samples. The objective was to demonstrate that the steel covers are watertight. Since at least one of the three covers has failed the water tightness test, the unverified assumption remains invalid. Licensee needs to address the status of the unverified assumption, and consequently its implication on the IWL examinations.
The licensee evaluation concluded that the containment remained fully operable by conservatively considering vertical tendon V213B is inactive. This condition was bounded by previous evaluations which considered multiple damaged/inactive anchors.
Observation: Semi-Annual Trend Review 71152 The inspectors reviewed action requests entered into the corrective action program for the following:
complete, accurate, and timely documentation of the issue identified in the corrective action program
evaluation and timely disposition of operability and reportability issues
consideration of extent of condition and cause, generic implications, common cause, and previous occurrences
classification and prioritization of the problems resolution commensurate with the safety significance
identification of corrective actions that are appropriately focused to correct the problem
completion of corrective actions in a timely manner commensurate with the safety significance of the issue
identification of negative trends associated with human or equipment performance that can potentially impact nuclear safety
operating experience is adequately evaluated for applicability, and applicable lessons learned are communicated to appropriate organizations and implemented The inspectors completed the review and noted a trend in the area of human performance in multiple departments associated with activities at the sight. Instances include two human performance issues involving work in high radiation areas (Action Requests 4404858 and 4405141), human performance issues involving maintenance on plant equipment (Action Requests 4407880 and 4409765) and human performance issues associated with the operations department (Action Requests 4404909 and 4431650). The licensee has documented the trend in human performance decline in Action Request 4404480 and additionally initiated a nuclear safety culture action plan documented in Action Request 4428447 to address the issue. The individual events will be reviewed by the resident or regional inspectors with results documented under the appropriate inspection activity if required. The resident staff will review the corrective actions to address the decline in human performance for effectiveness and will recommend follow up inspection in the biennial problem identification and resolution inspection scheduled for November 2021 in the areas of effectiveness of corrective actions and safety culture work environment.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 30, 2021, the inspectors presented the integrated inspection results to Mr. J. Washko, Site Vice President, and other members of the licensee staff.
On April 9, 2021, the inspectors presented the triennial heat sink inspection results to Mr. J. Washko, Site Vice President, and other members of the licensee staff.
On May 28, 2021, the inspectors presented the radiation protection inspection results to Mr. J. Ward, Site Maintenance Director, and other members of the licensee staff.
THIRD PARTY REVIEWS The inspectors reviewed the Institute on Nuclear Power Operations report that was issued during the previous inspection period.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
21 Summer Readiness Complete with Portions Unsat
(Exceptions)
06/07/2021
Procedures
LOS-ZZ-A2,
B
Summer Operation Preparations
Work Orders
Operations - LOS-ZZ-A2, Attachment B, Summerize Station
04/05/2021
M-101
Reactor Core Isolation Coolant, Sheet 1
BH
M-101
Reactor Core Isolation Coolant, Sheet 2
AT
Drawings
M-145
Standby Liquid Control System
LOP-SC-01E
Unit 1 Standby Liquid Control System Electrical Checklist
LOP-SC-01M
Unit 1 Standby Liquid Control System Mechanical Checklist
LOS-RI-Q3
Reactor Core Isolation Cooling (RCIC) System Pump
Operability and Valve Inservice Tests in Conditions 1, 2, and
LOS-SC-M1
SBLC Operability and Explosive Valve Continuity Check
Procedures
LOS-SC-Q1
SBLC Pump Operability/In-Service Test and Explosive Valve
Continuity Check
U2 RCIC S/P Check Valve Tst LOS-RI-R4,
Att 1A/LOS-RI-Q3, Att
04/18/2021
Work Orders
LOS-SC-Q1 1A SBLC Pump Quarterly Att 1A (Week 1)
06/07/2021
Fire Plans
FZ 4E2
AUX BLDG 731'-0" Elev. Auxiliary Equipment Room
97-197
Thermal Model of ComEd/LaSalle Station HPCS Diesel
Generator Jacket Water Coolers
A05
97-197
Thermal Model of ComEd /LaSalle Station 1B(2B) HPCS
Diesel Generator Jacket Water Coolers
A01
97-197
Thermal Model of ComEd/LaSalle Station HPCS Diesel
Generator Jacket Water Coolers
A04
RHR Pump A Cubicle Cooler Ventilation System
2C
L-001584 Rev.
001-001a
Volume of the Ultimate Heat Sink
04/15/2016
CSCS Cooling Water System RoadMap Calculation
4H
Calculations
VY01A Cooler Thermal Performance Model
08/26/2020
Corrective Action
Entered LOA-WL-001 B.6 for Low Lake Level
10/21/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Low Lake Level (<698.75') Makes Blowdown Temperature
Recorder Inop
11/04/2018
Entered LOA-WL-001 B.6 for Low Lake Level
2/20/2019
2VY04A DP Above Test Criteria During LOS-DG-SR5
04/12/2019
Outdated Input Used in Calculation L-002404, Rev 4
06/25/2019
2VY04A DP Test had Low Flow Before Replacement
10/11/2019
2VY04A Flow Before Replacement Did Not Meet Test Min of
230 GPM but Met 180gpm for Operable
10/11/2019
Entered LOA-WL-001 B.6 for Low Lake Level
10/15/2019
During LOS-DG-SR5 Measured DP for 2VY01A was High
11/14/2019
Low Flow on 2VY04A Before Replacement
11/14/2019
PPC Lake Water Level Not Trending as Expected
01/26/2020
Entered LOA-WL-001 B.6 for Low Lake Level
06/01/2020
As Found Coatings Inspection for 2B DG HX
07/24/2020
Abbreviated Maint: DG HX Reversing Head Coating Issue
06/24/2020
U1 and U2 Entered LOA-CW-101-201 After CW Inlet Lake
Temp Reached 99 deg
07/07/2020
NRC ID - Hydrographic Survey WO Record Incomplete
08/12/2020
Sludge Level Greater than 2 inches in Outlet Bay of Lake
Screen House
10/02/2020
1VY02A HPCS Pump Room Cooler DP Failed Test Criteria
11/25/2020
Documents
2VY01A DP Out of Acceptance Criteria Before Replacement
2/07/2020
Corrective Action
Documents
Resulting from
Inspection
NRC ID: 2B HPCS DG Cooler Tube Growth Rate Concern
04/08/2021
Drawing 0980
Diesel Generator Heat Exchanger Specification Sheet
C
Drawing
Ocean Surveys Inc. Contoured Depths 2020 Hydrographic
Survey Drawing 1
08/11/2020
Drawing
Ocean Surveys Inc Contoured Depths Additional Soundings
20 Hydrographic Survey Drawing 2
08/11/2020
Drawings
Drawing
Ocean Surveys Inc Contoured Depths Difference Map 2020
Hydrographic Survey Drawing 3
08/11/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawing
MP0442939
Air Handling Unit 1(2)VY01A
2/17/2018
Engineering
Changes
Thermal Margin of 1B DG HX with Tubes Blocked (L1R12)
Inspection
2/18/2008
LTS-1000-4 Evaluation of 2020 Lake Survey
10/22/2020
16-003
Operability Evaluation for Core Standby Core Cooling -
Essential Cooling Water (CSCS/VY) Coolers
Evaluation of the 1B DG Heat Exchanger Thermal
Performance Data Using Alternate (EPRI) Methodology
000
Evaluation of the 1B DG Heat Exchanger Thermal
Performance Data Using Alternate (EPRI) Methodology
000
1(2)VY02A DP ACCEPTANCE CRITERA
2/03/2020
Engineering
Evaluations
LAS-59000
Failure Analysis of Adapter, Water Outlet, 11 in. Diameter
Top Flange
08/06/2020
Miscellaneous
6037676CPDS-01
Coil Performance Data Sheet for CSCS Coolers 1VY01A
and 2VY01A
11/04/2019
Circulating/Service Water Chemistry
Heat Exchanger Electromagnetic Testing Methodology
Procedures
LES-DG-202
2E22-S001 Emergency Diesel Surveillance
LaSalle Pre-NRC Triennial Heat Sink
04/12/2018
Self-Assessments
LaSalle Pre-NRC Triennial Heat Sink
03/31/2021
(Finish) Eddy Current Test 2DG01A DG Cooling Water HX
09/29/2009
Diesel Generator Heat Exchanger Thermal Performance
Monitoring
05/08/2015
Diesel Generator Heat Exchanger Thermal Performance
Monitoring
01/14/2019
Eddy Current Exam Final Report
06/24/2020
1VY01A U1 Train A RHR Pump Room Cooler Cooling Water
Test
11/09/2020
2VY01A Initial LOS-DG-SR5 Division 1 Cooling Water Flow
Test
03/05/2021
1VY01A NW Area Cooler, Air Side Flowrate Test
11/09/2020
Work Orders
2VY01A LOS-DG-SR5 Att F Division 1 Cooling Water Flow
Test
2/08/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawing 1E-2-
216AA
Reactor Protection M-G Set Control System RP (C71B)
Part 1
S
Drawings
Drawing 1E-2-
4659AB
Internal Wiring Diagram Reactor Protection Sys RP (C71B)
D
LOP-RP-03
RPS Bus A Transfer
Procedures
OP-LA-108-117-
1000
LaSalle Protected Equipment Program
NRC Identified - Intercell Resistance Readings not Taken
09/28/2020
Air Void Found at 1RH03CB
03/29/2021
As Found Flow Low on 2VY02A During LOS-DG-Q3
05/23/2021
NRC Identified - Unit 2 Division 2 Switchgear Room
05/24/2021
Corrective Action
Documents
NRC Identified - Intercell Resistance Reading Sequencing
06/29/2021
Engineering
Changes
Evaluation of Scaffold Braced Off Safety Related 2VX02F
Supply Air Filter and Duct
LES-DC-101D
250 Volt Battery Inspection for Units 1 and 2
Scaffold Installation, Modification, and Removal Request
Process
MA-AA-716-025-
F-1
Non-Permanent Scaffold Request Form
Scaffold Installation, Inspection and Removal
Procedures
NES-MS-04.1
Seismic Prequalified Scaffolds
LEP-DC-113,
Unit 2 Division 3 125 Vdc Distribution Panel Changer
Installation
LOP-DC-01
Battery Charger Start Up and Shut Down
Procedures
PMOD 2-P135-21
Unit 2 Division 3 125 Vdc Temporary Charger
DG Oil Sensing Line Found Degraded
05/11/2021
License Renewal 0 DG Inspection Summary
05/11/2021
Corrective Action
Documents
DG Field Did Not Flash
05/13/2021
Procedures
LES-DG-100
0DG01K Emergency Diesel Unit Surveillance
L2R17 Contingency Work Order Needed for
03/14/2021
Work Orders
0DG033A Refurbish Pressure Regulator
05/07/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
LRA Perform I/V Plots Prior to Start-Up
03/13/2021
Measure SRM/IRM Drive Strokes
03/19/2021
Repair/Replace IRM Connectors
03/13/2021
Repair/Replace IRM Connectors
03/11/2021
(LR) 0DG01K Various U0 DG JW SS VLV Internal Inspection
05/07/2021
Small Oil Leak When Starting 0 DG
05/07/2021
Refurb or Replace 0DG Air Start Solenoid Valves per
LEP-DG-1
05/07/2021
0DG033A Refurbish Pressure Regulator
05/07/2021
Inspect 0 Diesel Generator Start Air Moisture Separator
05/07/2021
(LR) OTI on 0 DG L. O. Cooler Tubes
05/07/2021
LRA LOS-RI-Q5 U1 RCIC Cold-Quick Start, Att 1A
04/23/2021
Fatigue Assessment Performed on Allied Worker
03/03/2021
Corrective Action
Documents
Fatigue Assessment on Worker
03/17/2021
Corrective Action
Documents
Resulting from
Inspection
NRC Questioned Configuration of Constant Supports
04/16/2021
L2R18 SDS Plan
L2R18 Shutdown Safety Plan
LGP-3-5
RCS Pressure/Temperature Monitoring Special Log
Miscellaneous
Work Hour
Reports
Work Hour Rules Reports
Scram Time Rods per LOS-RD-SR12 & Flush Rods at 00 or
04/17/2021
Work Orders
U2 Core Verification (BOC Startup)
03/12/2021
LRA 'A' Train VE Recirc Filter Test (OVE01FA)
05/09/2019
Diesel Generator 2B 24-Hour Run Surveillance
04/21/2021
U2 RCIC S/P Check Valve TST LOS-RI-R4,
ATT 1A/LOS-RI-Q3, ATT 4A
04/19/2021
LOS-RH-Q1 1A RHR System, Att 1A
04/06/2021
LOS-VG-M1 U2 SBGT
04/20/2021
Work Orders
Semi-Annual Flex Generator Functional Run 0FF01KB
05/14/2021
Miscellaneous
MSA SCBA/Firehawk Monthly Inspection
04/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NISP-RP-003
Radiological Air Sampling
NISP-RP-008
Use and Control of HEPA Filtration and Vacuum Equipment
RP-AA-825-101-
1001
Operation and Use of the MSA Firehawk Self-Contained
Breathing Apparatus (SCBA)
Procedures
Replacement of Pre-Filters, HEPA Filters and Charcoal
Filters of Portable Air Filtration Equipment
Self-Assessments AR 4329355
71124.03 In-Plant Airborne Radioactivity Control and
Mitigation Self-Assessment
03/30/2021
Calibration
Records
PM-12 Calibration Data Sheet
11/02/2020
Internal Dose Control Program
Procedures
Exposure Control and Authorization
21-091600
Multiple Dosimetry EDE Evaluation Sheet
03/03/2021
Intake Investigation Form
03/08/2021
Radiation
Surveys
Intake Investigation Form
04/14/2021
Self-Assessments AR 4329355
71124.04 Occupational Dose Assessment Self-Assessment
03/30/2021
Certificate
00123456789
AMP 100 Calibration Record
2/30/2020
Certificate
00123456789
AMS-4 Calibration Record
10/20/2020
SN 902158
DMC3000 Calibration Record
06/10/2020
SN 916817
DMC3000 Calibration Record
06/10/2020
Post-Accident Division II Containment Gross Gamma
Radiation Monitor
10/14/2020
Calibration
Records
Station Vent Wide Range Gas Monitor Calibration
2/07/2020
Shepherd 89-400 Calibrator Failed Calibration
11/12/2020
SAMs at Line-4 Are Not Operating
2/08/2020
Corrective Action
Documents
Anomalies Identified SVS Low Range Detector Calibration
2/09/2020
Controls for Radiation Protection Instrumentation
Procedures
Operation of Air Samplers
Corrective Action
Documents
2G33-F001: Late Deferral of Committed Repair
03/02/2021
Drawings
M-143
Reactor Water Clean-Up
AT
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Engineering
Changes
EX 626108
Deferring Permanent Repairs to Valve 2G33-F001
Amendment to Commitments for Resolution of Anchor
Darling Double Disc Gate Valve Part 21 Issues
06/20/2017
RA19-005
2018 Regulatory Commitment Change Summary Report
01/14/2019
Miscellaneous
Recommendations to Resolve Flowserve 10 CFR Part 21
Notification Affecting Anchor Darling Double Disc Gate Valve
Wedge Pin Failures
Commitment Management
Procedures
Corrective Action Program (CAP) Procedure
Work Orders
Inspect and As-Found/As-Left Testing 2G33-F001
01/12/2021